Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
In the case before the Calcutta High Court, the petitioner sought relief regarding the additional tax liabilities arising from government contracts, irrespective of whether they were awarded before or after the introduction of GST. The court allowed the petitioner to file a representation before the Additional Chief Secretary, Finance Department, Government of West Bengal within four weeks. The Additional Chief Secretary is required to make a final decision within four months after consulting relevant departments and considering the petitioner's arguments. Until a decision is made, no coercive action can be taken against the petitioner.
In the case before the Calcutta High Court, the petitioner sought relief regarding the additional tax liabilities arising from government contracts, irrespective of whether they were awarded before or after the introduction of GST. The court allowed the petitioner to file a representation before the Additional Chief Secretary, Finance Department, Government of West Bengal within four weeks. The Additional Chief Secretary is required to make a final decision within four months after consulting relevant departments and considering the petitioner's arguments. Until a decision is made, no coercive action can be taken against the petitioner.
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